DAC6 Pulse - April 2020 - Issue 6

20/04/20

Hallmark of the Month: C.2

Periodically we highlight one of the key features ('hallmarks') of DAC6 in our Hallmarks of the Month Pulse editions. A transaction must fall within the scope of one of these 'hallmarks' in order to become reportable. The explanation and interpretation of the hallmarks is therefore very important.

In this edition, we discuss hallmark C.2. Hallmark C.2 concerns depreciation of assets, in situations where depreciation of one and the same asset is taken into account for tax corporate income tax purposes in more than one country, therefore a situation of potential double deduction. Read more about the Hallmark of the Month in this edition of the DAC6 Pulse.